Ezel / Tax Rulings / CT
CT Ruling 90-81 Sales and Use Taxes 1990-12-20

Were trucking, hauling, packaging, and custom-crating services subject to Connecticut sales tax, and who paid tax on crate materials?

Short answer: No under this historical ruling. Trucking and hauling were not enumerated taxable services, and packing, crating, and shipping were treated as personal services rather than sales of tangible personal property. The company was the consumer of lumber and other crate materials and owed Connecticut use tax on them. DRS marks the ruling not current and says it was modified by PS 94(1).

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1990 Connecticut Department of Revenue Services Ruling based on the described facts and law then in effect. DRS marks it 'not current' and says it was modified by Policy Statement (PS) 94(1). Treat its trucking, packaging, and crating classifications as historical and confirm the current rule. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Note -- modified historical guidance. DRS marks this ruling "not current" and says it was modified by Policy Statement (PS) 94(1). Verify current treatment before relying on it.

Plain-English summary

A trucking company picked up goods, transported them, and dropped them off using its own truck and driver. It sometimes also built custom crates and packed customer property for shipment.

DRS ruled that trucking and hauling did not fall within the enumerated taxable services. Packing, crating, and shipping were personal services, not sales of tangible personal property, and were also not subject to sales tax. The company was the consumer of materials used to build the crates and had to pay Connecticut use tax on those materials.

What this means for you

The historical ruling separated service revenue from the materials consumed in performing the service. But because PS 94(1) modified the ruling, current providers must check the later guidance.

Common questions

Were trucking and hauling taxable? No under the ruling.

Was custom crating a taxable property sale? No. DRS treated it as a personal service.

Who paid tax on crate materials? The service provider owed use tax as the consumer.

Citations and references

  • Policy Statement (PS) 94(1) -- identified by DRS as modifying this ruling.

Source

Original ruling text

Ruling 90-81, Trucking and Hauling Services / Packaging and Crating Services

This information is not current and is being provided for reference purposes only

Ruling 90-81

Trucking and Hauling Services

Packaging and Crating Services

This Ruling has been modified by   PS 94(1)

FACTS:

Company performs local and long distance trucking services which includes picking up goods from one location, transporting them to another location, and dropping off the goods. Company always furnishes a truck and driver for its transportation services.

In connection with its transportation and hauling services, Company is sometimes required to package and crate certain items of tangible personal property. These crates are often custom made by Company for its customers to securely pack the goods for shipment. Company pays Connecticut use tax on the materials used to build the crates.

RULING:

Trucking and hauling services do not fall within the categories of enumerated services subject to the sales and use tax.

Packing, crating and shipping is considered to be a personal service and not a sale of tangible personal property. Accordingly, such services are not subject to sales tax. Company is a consumer of the materials used in packaging and crating the goods and must pay use tax on the materials used to build the crates.

LEGAL DIVISION

December 20, 1990

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